1. 1 Spring Business Meeting Regional Haze SIP Development Survey San Francisco, California April 9, 2003

2. 2 PLANNING COMMITTEE Survey to Evaluate Resources Necessary to Develop a Regional Haze Control Plan Bob Habeck Montana DEQ

3. 3 OBJECTIVES Planning Committee recommendation to Council: - Summarize survey results and conclusions. - Discuss potential issues. - Discuss distribution process. - Seek Air Director approval.

4. 4 PURPOSE OF SURVEY “To Determine State Resources Needed to Prepare, Review, Approve, and Implement Regional Haze Visibility Control Plans 1.” 1 Source: November 7, 2001 letter to EPA Assistant Administrator Jeff Holmstead. WESTAR committed to preparing a report addressing this topic.

5. 5 SURVEY RATIONALE Results to be used by states in deciding between 308 and 309 strategies. Results to be use when working with EPA on SIP preparation, funding, and implementation issues. Results to be useful to WRAP committees to assist in prioritizing products that states are depending upon for SIP development.

6. 6 SURVEY TIMELINE Survey completed August 2002. Received responses from 15 states – one state responded to both 308 and 309 estimates. Preliminary data distributed to Air Directors on September 2002. Follow-up questions completed November 2002. Final Draft completed January 2003.

7. 7 SURVEY DESIGN Survey estimated resources needed beyond assistance from EPA / WRAP. Survey generic to both Section 308 & 309 tasks. Five phases of SIP Development: Project Planning; Development; Adoption; Approval; and Implementation (no comparisons)

8. 8 SURVEY DESIGN Assume SIP development process mostly generic between states. Resource units = ‘staff-weeks’ = 40-person hours completed in one week or several. Average estimates provide a reasonable estimate of resources for a ‘typical’ state.

9. 9 SURVEY DESIGN States were classified as either “Group A” or “Group B” based upon complexity: –Number of BART sources –Emission inventory complexity –Number of mandatory Class I areas GROUP ‘A’ GROUP ‘B’ WA CA NM9 CO ID SD ND HI OR MT AZ NM8AK UT NV WY

10. 10 SURVEY RESULTS SIP Develop Phase most resource intensive. Project Planning / Adoption / Approval Phases have similar workloads between 308 and 309. Could not differentiate work load between 308 / 309 approach due to insufficient responses. States assumed significant help from WRAP.

11. 11 VARIABILITY No state experience with RH plans. BART complexity and required workload. Complexity variation between states. Rules / programs required remain unknown. Workload predicted to update model inputs. Survey represents state ‘best guesses’.

12. 12 CONCLUSIONS Additional State resources are needed. Continued funding for WRAP is needed. Model rules would be beneficial to states.

13. 13 DISCUSSION POINTS: Use of survey as a solicitation for additional EPA funding. Survey results distribution process. Air Director approval. * END OF SLIDES *